Top 15 Most Common CMMC Compliance Mistakes Series #13
This article is part of our expert-led series: The Top 15 Most Common CMMC Compliance Mistakes (and How to Solve Them). Throughout this series, we're dissecting the frequent errors, misunderstandings, and misconceptions organizations encounter on their path to CMMC certification, drawing insights from seasoned CCPs, CISOs, and CCAs.
Today’s focus: We address the critical issue of understanding the boundaries of outsourcing within the context of CMMC compliance.
What You’ll Learn
- Which security controls can be outsourced and which cannot
- How to properly document outsourced responsibilities
- The implications of outsourcing on your System Security Plan (SSP)
- Best practices for managing external service providers within your compliance framework
Your Cybersecurity Outsourcing Could Cost Your Compliance
In the pursuit of CMMC compliance, organizations often engage external service providers (ESPs) to manage certain aspects of their cybersecurity infrastructure. While outsourcing can be beneficial, it's crucial to understand that not all responsibilities can be delegated. Misinterpreting these boundaries can result in non-compliance and potential security vulnerabilities.
Defining Outsourcing Boundaries
CMMC guidelines delineate specific responsibilities that must remain under the direct control of the Organization Seeking Certification (OSC). These include:
- Risk Management Decisions: The OSC must make final decisions regarding risk acceptance and mitigation strategies.
- Policy Development: While ESPs can provide input, the OSC is responsible for developing and approving cybersecurity policies.
- Security Control Implementation: Certain controls, especially those related to access management and incident response, require direct involvement from the OSC.
Conversely, tasks such as system monitoring, patch management, and routine maintenance can often be outsourced, provided that the OSC maintains oversight and ensures proper documentation.
Documenting Outsourced Responsibilities
When outsourcing permissible functions, it's imperative to:
- Establish Clear Agreements: Formal contracts should specify the scope of services, responsibilities, and expectations.
- Develop a Shared Responsibility Matrix (SRM): This document outlines which party is responsible for each security control, ensuring no gaps exist.
- Maintain Oversight: Regular reviews and audits of the ESP's performance help ensure compliance and address any issues promptly.
Implications for the System Security Plan (SSP)
The SSP must accurately reflect all outsourced services and delineate the responsibilities of both the OSC and ESPs. Failure to do so can lead to confusion during audits and potential non-compliance findings. Ensure that the SSP includes:
- Descriptions of Outsourced Services: Detail what services are outsourced and to whom.
- Responsibility Assignments: Clearly indicate which party is responsible for each control.
- Evidence of Oversight: Document how the OSC monitors and verifies the ESP's compliance with assigned responsibilities.
Managing External Service Providers
Effective management of ESPs involves:
- Due Diligence: Assess the ESP's capabilities, certifications, and compliance history before engagement.
- Regular Communication: Maintain open lines of communication to address issues and updates promptly.
- Performance Monitoring: Implement metrics and KPIs to evaluate the ESP's performance and compliance.
In Summary: Knowing Your Outsourcing Limits For Compliance
Understanding the boundaries of outsourcing is critical for CMMC compliance. While ESPs can provide valuable support, the OSC must retain control over specific responsibilities and ensure that all outsourced functions are properly documented and monitored. By clearly defining roles, maintaining oversight, and updating documentation accordingly, organizations can leverage external support without compromising their compliance posture.
Key Takeaways
- Not all cybersecurity responsibilities can be outsourced; the OSC must retain control over critical functions.
- Clear agreements and documentation are essential when engaging ESPs.
- The SSP must accurately reflect all outsourced services and delineate responsibilities.
- Regular oversight and performance monitoring of ESPs are crucial for maintaining compliance.
Up Next In Our Top 15 Most Common CMMC Mistakes Series:
In the next installment of our series, we'll explore how overlooking the value of external expertise to achieve full compliance costs businesses time and money.